2015-01-20_REVISION - P2009025 (6)

Home Browse Search

attached comments stating that I believed a solid first step is to determine what type of mining would be used as a guidance for placement of monitoring wells. The situation is serious because boring into a uranium deposit with a large amount of water could foreseeably cause the uranium to dissolve and create excursions of that water into surrounding drinking -water aquifers. The existing ISL rules allow for monitoring of excursions of uranium - laden solution by an array of monitoring wells chosen by a third party expert. There is no such rule for UBHM. How will the applicant demonstrate the ability to conduct the proposed mining operation without any leakage, vertical or lateral migration, or excursion of any leaching solution or groundwater - containing minerals, radionuclides, or other constituents mobilized, liberated or introduced by the process into any groundwater outside of the area? In their cover letter, Black Range Minerals proposes this protection using only one monitoring well; which is in conflict with the actual application, which states that where possible there will be from 2 -4 but up to 6 wells per drill pad location. Which is the case? What will be the location of these monitoring wells? Will they interfere with or be interfered by existing old prospecting holes? The applicant did not submit the maps required in application item H. 3. and 4. Perhaps the most important aspect of requirement for monitoring wells is that In Situ Leach (ISL) requires a confined aquifer, Underground Bore Hole Mining (UBHM) does not. By changing the rule for ISL to include UBHM, DRMS would be protecting the quality of groundwater used for domestic purposes and the Arkansas River. In these, and many other, respects the application is inadequate and should be denied. Open Public Process: Third, I would also like to make comment that I have no objection to DRMS requiring this type of mining to fall under the ISL rules. The same amount of public scrutiny should be applied to UBHM as is for ISL. Having been a party to the 2010 Rulemaking process for HB08 -1161, I understood that it was the Mined Land Reclamation Board's (MLRB) intent to protect groundwater quality not only during In -situ Leach operations; but for all Designated Mining Operations (DMO). This new type of DMO should not be approved under a NOI, but should be subjected to the full process of any DMO. To allow this process under a NOI is to allow a new uranium mining technique to escape the intent of DRMS's full reclamation permitting process with public input. The same public process should be undertaken before any UBHM operations are considered — especially at this the "pre- application" level. This is the level at which the current rules begin to shape the planning of an ISL process —it should be the same level at which DRMS should choose to shape any plans for UBHM; especially given the experimental nature and the unclear regulatory status of this endeavor. My first and foremost request is that the Department make a determination as to whether or not UBHM will be governed under the ISL rules in the application and review process of Rule 1.4 which allows for a Third Party Expert to be involved at the pre - application stage. Allowing this experimental type of process to proceed without caution is unthinkable, and against the stated goal of DRMS of being responsible for the "policy, regulation and planning" of mines. Now is the time to develop policies, regulations and planning for a type of mining that has never occurred before in